UK SRS compliance — ESG reporting requirements for UK companies
UK SRS is the UK’s sustainability disclosure framework, published on 25 February 2026. Compliance becomes binding through the FCA: under CP26/5, in-scope listed companies would report against UK SRS S2 climate from accounting periods beginning 1 January 2027, with Scope 3 and wider UK SRS S1 topics phased in on comply-or-explain.
UK SRS compliance is currently voluntary. Under FCA CP26/5, approximately 515 listed companies would be required to report against UK SRS S2 climate disclosures for accounting periods beginning 1 January 2027. Scope 3 emissions follow on comply-or-explain from 1 January 2028, with broader S1 sustainability disclosures from 1 January 2029.
Check who is in scope · Full implementation timeline · Readiness assessment · CSRD comparison
UK SRS compliance — what's at stake from 2027
UK SRS compliance means applying UK SRS S2 climate disclosure standards from 1 January 2027 (proposed) for around 515 UK-listed companies, with broader UK SRS S1 comply-or-explain from 2029.
UK SRS compliance is the obligation to apply UK SRS S1 and/or UK SRS S2 in published annual reports 1. For in-scope listed companies (UKLR 6, 16, 22), UK SRS S2 mandatory from 1 January 2027 is the headline date under the FCA’s CP26/5 proposal 2. Until the FCA Policy Statement publishes in autumn 2026, UK SRS compliance is voluntary — though both the FCA and DBT have signalled strong intent to deliver to the 2027 timetable.
A complete UK SRS compliance programme spans five workstreams: scope confirmation (UK SRS who is in scope), board and governance set-up, Scope 1/2/3 emissions inventory, scenario analysis and transition plan, and assurance-ready evidence packs 2. See the dedicated UK SRS compliance guide for step-by-step preparation. For the full UKSRS reference — UK Sustainability Reporting Standards.
What UK SRS compliance covers
The regulatory timeline, the scale of the regime, and where UK SRS sits against SECR and ESOS.
- 25 FEB 2026UK SRS S1 + S2 published
- AUTUMN 2026FCA CP26/5 Policy Statement
- 1 JAN 2027S2 climate for ~515 listed issuers (proposed)
- ~2028Scope 3 (comply-or-explain after 1-yr relief)
- ~2029Wider UK SRS S1 (after 2-yr relief)
UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 1, with the FCA proposing to embed the mandatory requirement through UK Listing Rules 2. The standards adapt the ISSB framework for UK conditions — UK SRS S1 adapts IFRS S1, and UK SRS S2 adapts IFRS S2 3.
Who must comply with UK SRS
Listed companies first under the FCA proposal; large private companies are not yet in scope but the Government is expected to consult through Modernising Corporate Reporting.
Who Must Comply: Listed Companies First
The FCA's proposal covers around 500 listed issuers across five UK Listing Rule categories.
Mandatory UK SRS S2 climate reporting is proposed from 1 January 2027; Scope 3 emissions follow on comply-or-explain after a one-year relief (effectively 2028); and wider UK SRS S1 disclosures follow after a two-year relief (effectively 2029).
Large private companies are not yet in scope, but the Government is expected to consult on them through the Modernising Corporate Reporting programme.
The five UKLR categories targeted by the FCA are UKLR 6, 14, 15, 16 and 22 2. Large private companies are currently subject to SECR under the Companies (Directors’ Report) Regulations 2018 4 and ESOS under the Energy Savings Opportunity Scheme Regulations 2014 5, but not yet UK SRS.
The four pillars — what UK SRS asks for
Governance, strategy, risk management, and metrics & targets. Disclosures connect to the financial statements, published at the same time, for the same period — on enterprise-value materiality, not double materiality.
UK SRS compliance means reporting across the four pillars that structure both standards — governance, strategy, risk management, and metrics and targets. For climate (UK SRS S2) that includes Scopes 1, 2 and 3, scenario analysis, and disclosure of any transition plan.
UK SRS Standards Framework
The four-pillar architecture is inherited from the TCFD framework 6 and the ISSB standards 3. For UK SRS S2, Scope 1, 2 and 3 GHG emissions must be measured in accordance with the GHG Protocol Corporate Standard 7. The FRC will oversee preparers’ compliance and has published detailed FAQ guidance on sustainability reporting developments 8.
- GovernancePillar 1
- Board oversight of sustainability-related risks and opportunities — who is accountable, how often the board considers them, how management supports the board.
- StrategyPillar 2
- How sustainability risks and opportunities affect business model, strategy and cash flows — including a transition plan if the company has one.
- Risk managementPillar 3
- Processes to identify, assess, prioritise and monitor sustainability-related risks and opportunities, integrated with the wider enterprise risk framework.
- Metrics and targetsPillar 4
- Scope 1, 2 and 3 greenhouse-gas emissions and any other industry-relevant metrics. See the full breakdown in our UK SRS S1 and S2 framework guide.
Comply or explain — what it actually means
For Scope 3 emissions and UK SRS S1 general sustainability, companies that do not disclose must explain — cite the paragraphs missed, give reasons, and set out steps and timeframe to disclose in future.
Transitional Relief Mechanism
For elements treated as comply-or-explain (Scope 3 emissions and UK SRS S1 general sustainability), companies that do not disclose must instead explain: identify the specific paragraphs of UK SRS they have not met, give their reasons, and set out the steps and timeframe to make those disclosures in future.
This follows the same discipline as existing TCFD-aligned rules.
The FCA expects companies to work toward full disclosure over time, with comply-or-explain providing transition relief rather than permanent exemption.
Under FCA CP26/5 2, the comply-or-explain provision for Scope 3 applies for one year from the mandatory start date; companies must explain which specific paragraphs they have not met, the reasons, and the timeframe for future disclosure. This mechanism mirrors the TCFD-aligned DTR disclosure rules 9 that applied to premium listed companies from accounting periods starting on or after 1 January 2021.
How to prepare for UK SRS compliance
Four-step preparation framework: gap analysis, data systems, board-level governance, voluntary early adoption. Scope 3 and S1 topics have the longest lead time — start there.
A gap analysis should map current TCFD-aligned reporting 6 against UK SRS S2 requirements. Scope 3 data collection typically takes 12-18 months to mature 2, making it the workstream with the longest lead time. The ICAEW has published practical sustainability reporting guidance 10 for preparers building compliance programmes.
UK SRS compliance — frequently asked
Is it mandatory, who has to comply, what does comply-or-explain mean, is assurance required, and how to prepare.
Is UK SRS compliance mandatory?
UK SRS is voluntary today, so there is currently no mandatory compliance obligation [1].
Compliance becomes binding through the FCA: under CP26/5, in-scope listed companies would be required to report against UK SRS S2 from accounting periods beginning on or after 1 January 2027 [6].
Who has to comply with UK SRS?
The FCA's proposal covers around 500 listed issuers across five UK Listing Rule categories [25] [7].
Large private companies are not yet in scope, but the Government is expected to consult on them through the Modernising Corporate Reporting programme [24].
What does comply-or-explain mean for UK SRS?
For elements treated as comply-or-explain (Scope 3 and UK SRS S1), a company that does not disclose must instead explain: identify the specific paragraphs of UK SRS it has not met, give its reasons, and set out steps and timeframe to make those disclosures in future [6].
Is assurance required for UK SRS compliance?
The FCA does not propose mandatory assurance, but in-scope companies must state whether they obtained third-party assurance over their disclosures [21].
The FRC is launching an interim sustainability-assurance practitioner register in mid-2026 [21].
How do I prepare for UK SRS compliance?
Run a gap analysis against your current TCFD-aligned reporting; build data systems for Scope 3 and wider S1 topics; establish board-level governance over sustainability data; and consider voluntary early adoption in 2026 to surface gaps before 2027 rules begin [6] [1].
When will large private companies need to comply with UK SRS?
Large private companies are not yet in scope of mandatory UK SRS.
The Government's Modernising Corporate Reporting (MCR) programme is expected to consult on extending UK SRS requirements to private companies — the scope is expected to follow existing SECR/NFRD thresholds (companies with 500+ employees or £500m+ turnover).
Timing has not been confirmed but companies should monitor MCR developments closely.
What are the consequences of not complying with UK SRS?
For listed companies, UK SRS reporting will form part of the FCA Listing Rules.
Non-compliance can result in FCA enforcement action, including public censure, financial penalties, and listing consequences.
Companies that neither comply nor provide an adequate explanation for comply-or-explain elements would be in breach of Listing Rules.
The FCA has committed to setting out its monitoring and enforcement approach in a future Primary Market Bulletin.
Related guides & references
UK SRS Overview
Company scope under FCA proposals and future extensions
FCA SDR and Anti-Greenwashing Rules
How FCA investment product rules differ from UK SRS corporate reporting compliance
UK SRS for Financial Services
Specific UK SRS requirements for banks, insurers, and asset managers
S2: Climate Disclosures
Climate compliance requirements — the four pillars and disclosure framework
UK Sustainability Regulation Timeline
When UK SRS compliance deadlines fall within the broader regulatory timeline
UK SRS Compliance Implementation Guide (srsreport.co.uk)
Step-by-step compliance checklists and practical implementation guidance
Sustainability Reporting Standards Compliance (sustainabilityreportingstandards.co.uk)
Detailed comply-or-explain mechanics and compliance obligation guidance
ICAEW Sustainability Reporting Guidance
Professional accounting institute guidance on sustainability reporting compliance
FRC Interim Sustainability Assurance Register
Financial Reporting Council register for sustainability assurance practitioners
ISSB International Sustainability Standards
Global baseline standards that UK SRS builds upon for international consistency
S1: General Sustainability
General sustainability disclosure requirements and reporting framework
Double Materiality
Understanding financial vs impact materiality in UK SRS context
Transition Plans
Climate transition planning requirements under UK SRS S2
SECR Reporting
How existing SECR rules interact with UK SRS compliance
ESOS Meaning
What ESOS means for UK energy assessment compliance
ESOS Phase 4
ESOS Phase 4 requirements and 2027 deadline